SUPREME COURT STATE OF NEW YORK

COUNTY OF NEW YORK

__________________________________________________X

R.J. CIPRIANI, aka ROBERT J. CIPRIANI,

aka ROBIN HOOD 702,
Index No. _________
Plaintiff, Date Purchased:
April 2, 2017

-v.- Plaintiff designates

NEW YORK
COUNTY as the
GLENN BUNTING and G.F.BUNTING+CO. place of trial.

Defendants. SUMMONS

____________________________________________________X
To the above named Defendant(s)

You are hereby summoned to answer the complaint in this action and to serve a
copy of your answer, or, if the complaint is not served with this summons, to serve a
notice of appearance, on the Plaintiffs' Attorney(s) within 20 days after the service of this
summons, exclusive of the day of service (or within 30 days after the service is complete
if this summons is not personally delivered to you within the State of New York); and in
case of your failure to appear or answer, judgment will be taken against you by default
for the relief demanded in the complaint.

Dated: New York, New York

April 2, 2017

Yours, etc.
Peter J. Gleason, PC

By:________//PJG//__________
Peter J. Gleason
Counsel for Plaintiff
935 South Lake Blvd.
Suite 17
Mahopac, New York 10541
(646) 872-3546
PJGleason@aol.com

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SUPREME COURT STATE OF NEW YORK
COUNTY OF NEW YORK
__________________________________________________X

R.J. CIPRIANI, aka ROBERT J. CIPRIANI,

aka ROBIN HOOD 702,

Plaintiff,
VERIFIED COMPLAINT
-v.- Jury Demand

GLENN BUNTING and G.F.BUNTING+CO.

Defendants.
____________________________________________________X

The Plaintiff R.J. CIPRIANI, by his attorney PETER J. GLEASON, PC, as and for his

complaint against defendants GLENN BUNTING and G.F.BUNTING+CO., respectfully sets

forth and alleges that:

INTRODUCTION

1. This is a defamation suit brought by CIPRIANI, aka ROBIN HOOD 702,

(hereinafter referred to as Cipriani), a philanthropist, professional gambler, activist and

husband of model/actress Greice Santo. GLENN BUNTING (Bunting) is a crisis management

public relations consultant. G.F.BUNTING+CO, (Bunting Co.) is a public relations firm,

founded by Glenn Bunting, based in San Francisco California, which according to their website

prides themselves as the anti-PR firm.

2. It is asserted that Glenn Bunting and Bunting Co., and their agents, purposefully

and with full knowledge of there falsity, verbally told a third party that Cipriani had committed

the crime of attempted extortion. This statement was unambiguous and directed to a third party

with the sole purpose to discredit Cipriani and destroy his relationship with said third party, The

New York Post. (Attempted extortion is a crime as defined under New York State Penal Law

155.10)
 3. The defamatory statement upon which this suit is predicated was a

conversation Bunting had with Richard Wilner, Business Editor of the NY Post. Wilner was

working on a story that was pitched by Cipriani, regarding Canadian billionaire Daryl Katz and

Katzs self-described cousin Michael Gelmon. The basis of the potential story was wire transfers

to Ciprianis wife totaling $35,000. The two wire transfers were from a penny stock, Banyon

Corporation, whose CEO at relevant time was Michael Gelmon. At relevant time Banyon

Corporation had a market cap of less than $1,000.

4. Upon information and belief either Katz or Gelmon either individually or in

concert with one another engaged Bunting and or Bunting Co., to destroy any chance that the NY

Post would run a story on the penny stock wire transfer and its more nefarious related backstory.

5. Upon information and belief: Bunting and or Bunting Co., in furtherance of

silencing the media regarding Katz and or Gelmon, engaged in communications with Richard

Wilner and other agents of the NY Post informing them that Cipriani was engaging in criminal

conduct, to wit, attempting to extort Katz and/or Gelmon. The statement(s) made by Bunting

and or Bunting Co. to the NY Post, irreparably caused substantial damage to Ciprianis

relationship with Wilner and the NY Post and Ciprianis philanthropy. The statement(s) made

by Bunting and or Bunting Co. regarding Ciprianis attempted extortion is undeniably false.

JURISDICTION AND VENUE

6. This Court has jurisdiction over Defendants pursuant to CPLR 302(a)(1).

Although a plaintiff may not establish personal jurisdiction over defamation defendants under

302(a)(2) and (3) of the CPLR, "courts will entertain defamation cases against non-domiciliaries

so long as jurisdiction exists under [CPLR] 302(a)(1)." Trachtenberg v. Failedmessiah.com, 43

F. Supp. 3d 198, 202 (E.D.N.Y. 2014); see also Best Van Lines, Inc. v. Walker, 490 F.3d 239,

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245-46 (2d Cir. 2007). This specific jurisdiction provision permits a court to exercise jurisdiction

over a non-domiciliary so long as two requirements are met: (1) the defendant "transacts any

business within the state; and (2) the "cause of action aris[es] from" that transaction. CPLR

302(a)(1). Transacting business for the purpose of CPLR 302(a)(1) requires "some act by

which [a] defendant purposefully avails itself of the privilege of conducting activities within the

Forum State, thus invoking the benefits and protections of its laws." Best Van Lines, 490 F.3d at

246 (quoting McKee Elec. Co. v. Rauland-Borg Corp., 229 N.E.2d 604, 607 (N.Y. 1967)).

However, "New York courts construe 'transacts any business within the state' more narrowly in

defamation cases than they do in the context of other sorts of litigation." SPCA of Upstate New

York, Inc. v. Am. Working Collie Ass'n ("SPCA"), 963 N.E.2d 1226, 1230 (N.Y. 2012) (quoting

Best Van Lines, 490 F.3d at 248). Under 302(a)(1) in the defamation context:

[T]he single act of uttering defamation, no matter how loudly, is not a transaction

of business that may provide the foundation for personal jurisdiction. In other words,

when the defamatory publication itself constitutes the alleged transaction of business . . . ,

more than the distribution of a libelous statement must be made within the state to

establish long-arm jurisdiction over the person distributing it.

7. Bunting and Bunting Co., acknowledge their extensive transactional business

connections to New York, hereby overcoming any objection by Defendants to jurisdiction. To

wit, the following is from the Defendants web site: Heidi Davidson joins G.F. BUNTING+CO

to support the growth of the firms rapidly expanding New York practice. According to related

press coverage of Ms. Davidson she joined Bunting Co. in mid 2015.

PLAINTIFF

8. Plaintiff, a male citizen of the United States of America over twenty-one (21)

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years of age, resides in Los Angeles County and the State of California. Prior to the ruinous

statement(s) giving rise to this suit, Cipriani was a well-known and respected source for Richard

Wilner of the Business Editor of The New York Post. Cipriani, while embracing the

complexities of the modern world, comes from the simplest of backgrounds. The son of a first

generation Italian American barber Plaintiff grew up on the wrong side of the tracks in

Philadelphia. Plaintiff was reared by his parents while also caring for 4 other children in

cramped quarters above the fathers barbershop. This closeness generated a strong sense of

loyalty and the necessity for honesty. Without these attributes, survival in such close quarters

would have been untenable. Based on this filing, Cipriani not only expects the Defendants to

further attempt to malign his character, he welcomes it. Cipriani is of the opinion that Bunting

enables certain high paying clients to circumvent liability for sexual misconduct. Bunting and

Bunting Cos professional relationship with Florida State University, Baylor University and

Occidental College come to mind. The reprehensible and vile filth that Bunting and Bunting Co.

seeks to cover up through their media strategy is as sick and twisted as communicating to the NY

Post that Cipriani attempted to extort Katz and or Gelmon. Bunting on the Bunting Co. website

shares with the world his passion for his grandchildren: How would he feel if one of his

grandchildren lived the horrors suffered by the victims at Florida State, Baylor University or

Occidental College only to have some media consultant then publically abuse them?

DEFENDANTS

9. Glen Bunting is Founder and President of G.F.BUNTING+CO. Bunting and his

firm advertise itself on the internet as an expert in creating original content and as experts in

strategic communication, and they publicly tout their many friends and former colleagues

who work at the nations leading newspapers, TV networks and online news organizations.

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Buntings reference to creating original content conjures up the term du jour, Fake News.

10. Bunting in a most reckless manner has described his client base as those who have

engage[d] in some kind of misconduct they should have not engaged in. In legal terms this

would be tantamount to making statements against your clients self interest. Bunting, not being

an attorney himself, might self-reflect in hindsight, and recognize that said statement throws his

current and prospective client base under the bus, thus acknowledging his clients culpability.

11. Defendants aggressive and ruthless media manipulations frequently involve

whitewashing the national epidemic of the sexual abuse of women. Some glaring examples of

Buntings handiwork include;

a. Florida State University, (FSU), hired G.F. Bunting, a communications

firm in San Francisco specializing in crisis management, to counter the

storyline of the film, the The Hunting Ground, which depicts the rape epidemic on

college campuses throughout the United States. FSUs segment in the The

Hunting Ground is about Erica Kinsman, who describes being locked in and

pinned to a bathroom floor, having her head slammed against the tile and being

forcefully raped while she is begging the attacker to stop. She went to the

emergency room. She did the rape kit. She later recognized her attacker as Jameis

Winston, at the time Florida State Universitys rising star quarterback, now a

Heisman trophy winner and this years number one pick in the NFL draft. There

was a DNA match. According to the film, Florida State delayed the investigation

for 18 months, while Winston continued winning football games.

b. According to the Huffington Post, They (Bunting Co.) play hardball.

In 2013, the LA Times ran a story in 2013 about Occidental College failing to

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report 27 sexual assaults on their campus. Occidental hired G.F. Bunting. Bunting

was able to have the story taken down only to subsequently have Occidental

officials later admit that they had, in fact, failed to report 27 assaults and that they

had been legally required to do so.

c. Baylor University retained the services of Bunting Co. to deal with crisis

management regarding yet another college campus sex scandal involving

allegations of rape. There was a related civil action filed on December 8, 2016

and shortly thereafter on or about February 1, 2017 was withdrawn. The

circumstances of the withdrawal are unclear which raises the specter that it may

have been quietly settled with a non-disclosure agreement in place. Bunting and

Bunting Co. were not named defendants in the Baylor action and Bunting has

made no attempt to clear his or his companys name regarding certain

unfavorable characterizations throughout the Baylor action. Plaintiff, by way of

reference, incorporates those sections of the Baylor action that references the

manner in which Bunting and Bunting Co. professionally comport themselves.

Please find heretofore attached and marked Exhibit A. Here is the caption of the

Baylor action:

CAUSE NO. 19980

ART BRILES IN THE DISTRICT COURT OF

Plaintiff,

VS. LLANO COUNTY, TEXAS

J. CARY GRAY
RONALD DEAN MURFF
DAVID HARPER
REAGAN RAMSOWER
Defendants. 424TH JUDICIAL DISTRICT

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 12. Bunting Co. boasts that they have many friends and former colleagues who work

at ... The New York Times, Los Angeles Times, Wall Street Journal, Bloomberg, BusinessWeek,

the Washington Post, Forbes, Fortune, San Jose Mercury News, The Miami Herald, CBS, NBC

and ABC News, The Associated Press, Reuters and The Huffington Post.

13. Upon information and belief, Bunting and Bunting Co. uses their many friends

in the media to assist those who engage in some kind of misconduct they should have not

engaged in. Apparently in a number of occasions, in furtherance of silencing and/or discrediting

those that have been sexually victimized.

14. Furthermore, Bunting boasts on his company website, every one of our senior

executives served as respected members of the Fourth Estate. This is disturbing on many

levels. The implications are clear based on the historical analysis of what the meaning and

implications are regarding the Fourth Estate. In 1580 Montaigne proposed that governments

should hold in check a fourth estate of lawyers selling justice to the rich and denying it to

rightful litigants who do not bribe their way to a verdict. The modern day metamorphosis of the

Fourth Estate has evolved into the medias ability to silence the truth for the highest bidder.

15. Bunting and or Bunting Co. may have fallen prey to their own self-proclaimed

success in covering up sexual assault and or misconduct as evidenced by Buntings own words in

this youtube video: https://www.youtube.com/watch?v=zYwoQYtPOVM

16. In the video, Bunting smugly professes that he gets the call after the house is

fully engulfed in flames, this after the potential client has engage[d] in some kind of

misconduct they should have not engaged in. Buntings self-indictment of his (Buntings)

client base brings into question not only Buntings business acumen but the veracity of any

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denials Bunting may proffer on behalf of his clients to his or his companys many friends and

former colleagues who work at the nations leading newspapers, TV networks and online news

organizations.

17. Upon information and belief Bunting and Bunting Co. have lulled themselves into

the false belief that he and/or his company are impervious to any legal or moral accountability.

18. A very wise man once said, When you have your hand in the mouth of the tiger,

you pull it out very slowly. In applying this to the instant matter, Bunting through sheer

arrogance may have met his Waterloo in the form of a kid from the wrong side of the tracks in

Philadelphia.

19. While Bunting and Bunting Co. acknowledge their extensive transactional

business connections to New York, they should have done some homework. The New York

press corp., particularly the NY Post, does not look favorably upon those who lie to them or

embolden sexual predators. By way of example, the eventual downfall of one of New Yorks

most powerful men, Sheldon Silver, can be directly linked to the NY Posts exposing Silvers

cover-up of the sexual assaults of his (Silvers) Chief of Staff, Michael Boxley.

20. Glenn Bunting is a dichotomy, in one respect a self-professed doting grandfather

and his mutually exclusive alter ego of a rape enabler.

PROCEDURAL REQUIREMENTS

21. Plaintiff by dint of a letter to GF Bunting, dated January 16, 2017, requested that

Bunting retract the defamatory statement he (Bunting) made to the NY Post. To date, Bunting

and or Bunting Co. have yet to respond.

BACKGROUND

22. The backstory to Buntings zealous yet inappropriate invocation is, upon

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information and belief, related to Buntings representation of Canadian billionaire Daryl Katz

(Katz).

23. By any standard, Katz is not a handsome man. What he lacks in physical

presence, he tries to overcompensate with his bankroll. Upon information and belief, one way in

which Katz encounters beautiful women is through a magazine called Viva Glam.

24. Upon information and belief, Viva Glam is a front for Katz to procure beautiful

women for his own personal pleasure. One such photo shoot, in Hawaii, included Plaintiffs

wife where Katz assisted by Gelmon inappropriately pursued Plaintiffs wife that resulted in an

alienation of affection, claim by Plaintiff and a Criminal Complaint filed by Plaintiffs wife.

25. Hawaii recognizes the tort of alienation of affection, and both Katz and Gelmon

retained counsel to represent them against Plaintiffs claim.

26. There were confidential settlement negotiations, which one of Katz/Gelmon

lawyers memorialized, from their perspective, in writing and upon information and belief

inappropriately provided to Bunting and or Bunting Co.

27. Plaintiffs wife is no stranger to being pursued by rich powerful men, and with the

exception of Katz/Gelmon, it was always done with a certain je ne sais quoi. Some of Plaintiffs

wifes suitors included Leonardo DiCaprio. Axl Rose, John Stamos, and Jim Carrey. All of

whom accepted no for an answer.

28. The totality of Katz/Gelmons inappropriate behavior can be found in the criminal

complaint that Plaintiffs wife filed with the Culver City Police Department # 16-27085 on July

10, 2016, which was forwarded to Chief Harry Kubojiri of the Hawaii Police Department, that is

heretofore attached and marked Exhibit B.

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 FACTUAL ALLEGATIONS

29. Plaintiffs claim, while simple and straightforward, necessitated the

aforementioned background as it directly relates to the Defendants motivation in falsely

accusing the Plaintiff of a crime: attempted extortion.

30. On or about July 11, 2016, Defendants Bunting and or Bunting Co. told Richard

Wilner of the NY Post that Plaintiff was involved in an extortion plot against Katz and/or

Gelmon.

31. Defendants, Bunting and or Bunting Co. knew, or at a minimum, should have

known that the statements regarding Plaintiff that they told to Richard Wilner were false.

32. The aforementioned amounts to slander per se.

33. Because of Defendants slanderous accusations, Plaintiffs relationship with

Richard Wilner has been irreparably harmed.

34. Plaintiffs claim exceeds the jurisdictional limit of the Court below.

JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues of fact and damages stated

herein.

Dated: New York, New York

March 26, 2017

Yours, etc.
Peter J. Gleason, PC

By:________//PJG//___________
Peter J. Gleason
Counsel for Plaintiff
935 S. Lake Blvd.
Suite 17
Mahopac, New York 10541
(646) 872-3546
PJGleason@aol.com

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